Suspension of tax limitation. A resolution can be expected soon

Suspension of tax limitation. A resolution can be expected soon


Can courts control whether the tax office has instituted criminal fiscal proceedings solely to prevent time limitation of a tax liability and therefore give itself more time to complete the tax proceedings?

This question is supposed to be answered on 17 May this year by the Supreme Administrative Court. A corresponding request was submitted in December 2020 by the spokesman of small and medium-sized enterprises.

Comment by Andrzej Ladziński, the originator and co-author of the report "Instrumental initiation of criminal fiscal proceedings during audit and tax proceedings", a partner of the GWW law firm, was published in today's issue of Dziennik Gazeta Prawna:,wstrzymywanie-podatkowego-przedawnienia-kiedy-uchwala-nsa.html 

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